1. Home
  2. |Insights
  3. |FEHBP Final Rule on Provider Sanctions

FEHBP Final Rule on Provider Sanctions

Client Alert | 1 min read | 03.08.04

The Office of Personnel Management ("OPM") has issued a final financial sanctions rule for health care providers participating in the Federal Employees Health Benefits Program ("FEHBP"). Two categories of financial sanctions are established by the March 3 rule: assessments, which are intended to recognize losses, costs, and damages incurred as the result of a provider's wrongful conduct, and civil monetary penalties, which are lump-sum amounts that, while computed by reference to improper claims, are intended principally to deter future violations. The bases for financial sanctions are (1) fraudulent or improper claims; (2) false or misleading statements in or about claims; and (3) failure to provide claims-related information that is required by law to be disclosed. Sanctions may be imposed only for violations that directly involve FEHBP enrollees, carriers, or funds. The final rule sets forth the procedures for imposing, determining the amount, and collecting financial sanctions, as well as providers' right to contest and appeal the imposition of financial sanctions. The March 3 final rule also clarifies the circumstances under which payments may be made from FEHBP funds to suspended providers. This rule, along with the rule governing suspension and debarment of FEHBP providers, implements the administrative sanctions enacted by the Federal Employees Health Care Protection Act of 1998 (Pub. L. 105-266).

Insights

Client Alert | 15 min read | 08.20.25

The New EU “Pharma Package”: Interplay with the Critical Medicines Act and other shortage initiatives

In this eighth alert in our weekly series on the EU Pharma Package, we continue our overview of initiatives with respect to security of supply and shortage prevention and mitigation. Our last alert looked at how the Pharma Package seeks to address these issues. However, the Pharma Package does not exist in isolation, and in this alert we will discuss the interplay between its measures and those contained in other important EU initiatives such as the proposed Critical Medicines Act (CMA), and the Medicinal Countermeasures Strategy and the EU Stockpiling Strategy....